9/8/15 - CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $45,000.
ALLEGATIONS:
ON DEC 19, 1991, EPA ISSUED TO RESPONDENT 5 UIC PERMITS FOR THE SUBJECT WELLS.
THE OPERATING REQUIRMENTS FOUND IN THE PERMITS ESTABLISH THE MAXIMUM WELLHEAD INJECTION PRESSURE LIMITATION FOR EACH WELL IN ACCORDANCE WITH 40 CFR 146.23(a)(1) AS MEASURED IN POUNDS PER SQUARE INCH GAUGE (PSIG).
BASED ON EPA'S RECORDS AND INSPECTION REPORTS, RESPONDENT EXCEEDED THE MAXIMUM WELLHEAD INJECTION PRESSURE LIMITATIONS ESTABLISHED BY THE UIC PERMITS FOR THE FOLLOWING ACTIVE PERMITTED WELLS:
TAYLOR #1-W, INSPECTION DATE 6/16/14; RECORDED PRESSURE 1,500 PSIG; PERMIT LIMIT 1,200 PSIG;
TAYLOR #2-W, INSPECTION DATE 6/16/13; RECORDED PRESSURE 1,500 PSIG; PERMIT LIMIT 1,170 PSIG;
TAYLOR #8-2; INSPECTION DATE 6/18/14; RECORDED PRESSURE 1,500 PSIG; PERMIT LIMIT 1,170 PSIG.
THEREFORE, RESPONDENT IS IN VIOLATION, 40 CFR 146.23(a)(1) AND 144.51(a) AND THE UIC PERMITS FOR EXCEEDING THE MAXIMUM INJECTION PRESSURE LIMITATIONS ESTABLISHED FOR THE ACTIVE PERMITTED WELLS.
THE PERMITS REQUIRES THE PERMITTEE TO CONDUCT AN INJECTION FLUID ANALYSIS IN ACCORDANCE WITH 40 CFR 146.23(b)(1) AT LEAST ONCE EVERY 12 MONTH AND WHENVER CHANGES ARE MADE TO THE INJECTION FLUID. THE PERMITS REQUIRE THE PERMITTEE TO ANNUALLY SUBMIT THE RESULTS OF INJECTION FLUID ANALYSES TO EPA IN ACCORDANCE WITH 40 CFR 146.23(c).
INJECTION FLUID ANALYSIS RESULTS FOR THE FOLLOWING ACTIVE PERMITTED WELLS WERE NOT ANNUALLY S